CPA - medium firm
CPA - large firm
Enrolled Agent
Other
Non-resident investment in United States real property is subject to tax under the Foreign Investment in Real Property Tax Act, under unique rules not directly analogous to any other American tax regime. Included within this program is coverage on where and how the FIRPTA regime applies its application to American corporate entities holding real estate. Guidance on how the FIRPTA rules correlate with general non-resident tax rules (folding nonresident real estate investment into the effectively connected income category) will be provided, as well as mechanisms for avoiding otherwise applicable withholding requirements.
Learning Objectives:
- Recognize differences in nonresident ECI and FDAP income
- Determine conditions to treat income generated by American real property as ECI
- Recall tax implications of FIRPTA
Patrick McCormick, JD, LLM
Culhane Meadows, PLLC
Partner
pmccormick@cm.law
(215) 630-0861
Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.
Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law. His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.
Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.
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